To follow up on the post from yesterday regarding the use of these “lockout devices”, I was reminded by many of you in the same camp as me, that these devices are also highly questionable when we look at their ability to meet the “substantial“ requirement. These safety pros all agreed that the use of these devices, and in fact any plastic lockout device, comes under great scrutiny at their companies. They were quick to agree that these plastic clam shells would never be permitted, although several of them did say that metal ones may pass their test, but would still not allow these lockout devices to be used. Unfortunately, I am not at liberty to call out company names, but these are major employers around the globe.
1910.147(c)(5)(ii)(C) Substantial –
1910.147(c)(5)(ii)(C)(1) Lockout devices. Lockout devices shall be substantial enough to prevent removal without the use of excessive force or unusual techniques, such as with the use of bolt cutters or other metal cutting tools.
From OSHA’s CPL, 02-00-147, The Control of Hazardous Energy – Enforcement Policy and Inspection Procedures
Substantial. Protective materials and hardware must be substantial enough to minimize the likelihood of early or accidental removal. Other than using a key or combination to remove a lock, employees must be able to remove locks only by using excessive force with special tools, such as bolt cutters or other metal-cutting tools.
Additionally, the lockout device must be substantial enough to prevent removal without the use of unusual techniques. For example, the use of nylon cable ties would NOT be an appropriate substitute for more traditional and substantial lockout devices, such as the use of locks and chains to hold a valve in the safe position. While a cable tie is a positive means of holding the energy isolating device in a safe position, nylon ties are generally removable through the use of common cutting tools (e.g., pocket knives, side cutters, or scissors) or by releasing the pawl mechanism with a device such as screwdriver; neither of which constitutes an “unusual technique,” as required by the standard.